Hubbell Policies

DERIVATIVES AND HEDGING POLICY

English

Owner : Assistant Treasurer

Last Review: 201 9 . 08 .1 5

FIN – 21

Department: Treasury

POLICY All hedging contracts will be reviewed and approved by the Corporate Treasurer or the Corporate Chief Financial Officer as required by the Corporate Authority Matrix.

Derivative transactions are to be used to hedge, mitigate or reduce commercial risk exposures.

Derivative transactions may not be used for speculative purposes or to assume risks that are not prudent considering the purposes for which the transaction is intended. The use of leverage is strictly forbidden. SCOPE The Policy and any sub-policies that it may govern are applicable to all Hubbell legal entities. PURPOSE The purpose of the Hubbell Incorporated "Hubbell" Derivatives and Hedging Policy, "the Policy" is to provide governing parameters surrounding the use of derivative instruments, contracts and hedging activities to mitigate commercial risk and to support compliance with new regulations adopted under the Dodd-Frank Wall Street Reform and Consumer Protection Act “Dodd-Frank” and the European Market Infrastructure Regulations "EMIR". PROCEDURE All hedging contracts will be reviewed and approved by the Corporate Treasurer or the Corporate Chief Financial Officer as required by the Corporate Authority Matrix. Derivative contracts should only be entered into to offset risk associated with exposures related to existing or reasonably anticipated company underlying assets, liabilities and transactions. Examples of these exposures include currency fluctuations, interest rate volatility and commodity cost variation.

At a minimum, the following risks should be considered for each derivative transaction:

1. Counterparty Risk - the risk that the counterparty will not fulfill its obligations under the contract.

2. Termination Risk - the risk that the contract would be terminated as a result of various events.

3. Tax Risk - the risk due to changes in income tax rates and other changes in tax policy.

Hedge Program Guidelines Risk management of interest rate, foreign exchange or commodity exposures will only be undertaken in the context of hedging or protecting underlying financial exposures (i.e.: mitigating commercial risk). Speculation of any kind is strictly prohibited.

76